library


SAMPLE FEDERALWIDE ASSURANCE (FWA) MOUS

MOU 1: Agreement between NPC and VAMC

Use MOU 1 when the NPC and VAMC Use a VA IRB

This MOU fulfills the Office for Human Research Protections (OHRP) requirement that both parties must put in writing their respective responsibilities in assuring the protection of human subjects when an assuring institution (NPC) is involved in cooperative research with another organization (VAMC) and relies on the other organization’s (VAMC) IRB.

Consistent with the authority provided in 38 CFR §16.114, NPC established under 38 USC §§7361-7368 and VAMC wish to avoid duplication of effort in the oversight of cooperatively conducted human studies research. Recognizing that NPC research is VA-approved research subject to policies and procedures contained in VA manuals, regulations and statutes, NPC and VAMC agree that all oversight for such studies will be provided by VAMC and its IRB including:

  1. Monitoring review and approval of projects and related documentation to ensure compliance with human subject protection requirements
  2. Monitoring the performance of studies to ensure compliance with human subject protection requirements
  3. Providing investigators and other relevant personnel with mandatory training and monitoring compliance with training requirements

The only exception is that the NPC Federalwide Assurance (FWA) signatory official must complete the required initial and continuing training and is responsible for ensuring that relevant NPC employees also do so.

NPC relies on VA handbooks, regulations and statutes as well as local VAMC, R&D Committee and IRB policies and procedures regarding communication among relevant parties and sharing of documentation.

 

_________________________________
VAMC Official

 

_________________________________
IRB Chairman

 

_________________________________
NPC Official

 

_________________________________
VAMC Human Protections Administrator

 

MOU 2: Agreement Between NPC, VAMC and University IRB

Use MOU 2 When NPC and VAMC Use a University IRB

This MOU fulfills the Office for Human Research Protections (OHRP) requirement that all parties must put in writing their respective responsibilities in assuring the protection of human subjects when an assuring institution (NPC) is engaged in cooperative research with other organizations (VAMC and University) and relies on another organization’s (University) IRB.

Consistent with the authority provided in 45 CFR §46.114 and 38 CFR §16.114, the NPC established under 38 USC §§7361-7368, VAMC and University wish to avoid duplication of effort in the oversight of cooperatively conducted human studies research. Recognizing that NPC research is VA-approved research subject to policies and procedures contained in VA manuals, regulations and statutes, NPC, VAMC and University agree that all oversight for such studies will be provided by VAMC and the University IRB consistent with:

1) University IRB operating policies and procedures (insert reference to documentation appropriate for University IRB); and

2) Existing or subsequent VAMC - University agreements assigning respective responsibilities.

Subject to 1) and 2) above, such VAMC and University oversight will include:

  1. Monitoring review and approval of projects and related documentation to ensure compliance with human subject protection requirements
  2. Monitoring the performance of studies to ensure compliance with human subject protection requirements
  3. Providing investigators and other relevant personnel with mandatory training and monitoring compliance with training requirements

The only exception is that the NPC Federalwide Assurance (FWA) signatory official must complete the required initial and continuing training and is responsible for ensuring that relevant NPC employees also do so.

NPC relies on VA handbooks, regulations and statutes as well as local VAMC, R&D Committee, University and IRB policies and procedures regarding communication among relevant parties and sharing of documentation.

Signatories (as appropriate for local circumstances):

 

_________________________________
University Official

 

_________________________________
VAMC Official

 

_________________________________
IRB Chairman

 

_________________________________
University Human Protections Administrator

 

_________________________________
VAMC Human Protections Administrator

 

_________________________________
NPC Official

 

Home | About NAVREF | Professional Development | Library | Advocacy | Legal Resources | For Clinical Research Sponsors

last updated: 01/31/08

 

©2008, National Association of Veterans' Research and Education Foundation.  All rights reserved.